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Comparison

Read two legal systems against each other

Because every portal follows the same fifteen-section outline, the comparison is genuinely like-for-like rather than a collage of whatever each government happens to publish.

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Comparison of selected legal systems
AttributeIranReviewedNamibiaReviewedMyanmarReviewed
Legal familyIslamic law with civil law codificationMixed Roman-Dutch and English common lawCommon law with codified statutes
System of governmentIslamic republicSemi-presidential republicMilitary administration; constitutional order suspended
ConstitutionConstitution of the Islamic Republic of IranConstitution of the Republic of NamibiaConstitution of the Republic of the Union of Myanmar
In force since197919902008
CapitalTehranWindhoekNaypyidaw
Official languagesPersianEnglishBurmese
CurrencyRial (IRR)Namibian dollar (NAD)Kyat (MMK)
Population89,000,0002,600,00054,500,000
Division of powersUnitary, with 31 provinces headed by governors-general appointed by the Interior Ministry, alongside elected city and village councils created by the Constitution and operating since 1999 with limited competences.Unitary with 14 administrative regions and elected regional councils, which also constitute the National Council, the upper chamber. Traditional authorities exercise recognised functions over communal land and customary law.Nominally a union of seven regions, seven states, one union territory and six self-administered zones and divisions, each with its own legislature under the 2008 Constitution. In practice the region and state legislatures are suspended or subordinated to the military administration, and chief ministers are appointed centrally.
How law is madeA bill is introduced by the Government or by at least fifteen deputies, passes the Majlis, and goes to the Guardian Council, which has ten days, extendable, to find it consistent with Islam and the Constitution. If the Council objects, the bill returns for amendment; persistent disagreement goes to the Expediency Discernment Council, whose decision is final. Only then does the President sign and publish.Bills pass the National Assembly through three readings, then go to the National Council for review. The Council may confirm, propose amendments, or object; the Assembly can override an objection by a two-thirds majority. The President then assents, and constitutional amendments require two-thirds of both chambers and may never diminish the rights chapter.Under the 2008 Constitution, bills passed both chambers and went to the President, with disagreements resolved in joint sitting. Since February 2021 legislation is made by the State Administration Council as law or order, published in the Gazette without legislative passage, and a series of such instruments has amended the Penal Code, the electronic communications law and the criminal procedure code.
Legal professionTwo parallel routes to practice, which is unusual and consequential: attorneys licensed by the Iranian Bar Association (Kanoon-e Vokala), a self-governing body dating to 1953, and attorneys licensed under Article 187 of the Third Development Plan directly by the judiciary. The two groups have contested each other's standing for two decades. Notaries operate licensed offices under the registration organisation, and their authentication is required for property transfers, marriage contracts and powers of attorney.A fused profession under the Legal Practitioners Act: a single class of legal practitioner is admitted after a law degree and the Justice Training Centre's postgraduate course, and the Law Society of Namibia regulates practice.Advocates and higher-grade pleaders are admitted under the Legal Practitioners Act 1879 and the Bar Council Act 1929, an inherited colonial framework, with the Supreme Court controlling the roll. Independent bar associations formed after 2011 but the Bar Council has long been closely supervised, and lawyers acting in political cases have themselves faced prosecution and disbarment since 2021. Legal aid exists under the Legal Aid Law 2016 but is thinly resourced.

A comparison table flattens nuance by design. Where a difference matters to a decision you are making, open both portals and read the section in full — the constitutional detail behind a one-line summary is often the part that governs the outcome.